20240904PAC to Staff 65 - 1st Revised.pdf

1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
September 4, 2024
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Ste. 201-A
Boise, ID 83714
[e-mail]
[e-mail]
RE: ID PAC -E-24-04
IPUC Set 5 (58-81)
Please find enclosed Rocky Mountain Power’s 1st Revised Response to IPUC 5th Set Data
Request 65. Provided via BOX is Confidential Attachment IPUC 65 1st Revised . Confidential
information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the
Idaho Public Utilities Commission’s Rules of Procedure No. 67 – Information Exempt from
Public Review, and further subject to the non-disclosure agreement (NDA) executed in this
proceeding.
If you have any questions, please feel free to call me at [phone].
Sincerely,
____/s/____
Mark Alder
Manager, Regulation
Enclosures
C.c.: Eric L. Olsen/IIPA [e-mail] (C)
Lance Kaufman/IIPA [e-mail] (C)
Matthew Nykiel/ICL [e-mail]
Brad Heusinkveld/ICL [e-mail]
Thomas J. Budge/Bayer [e-mail] (C)
Brian C. Collins/Bayer [e-mail]
Greg Meyer/Bayer [e-mail]
Kevin Higgins/Bayer [e-mail] (C)
Neal Townsend/Bayer [e-mail] (C)
Ronald L. Williams/PIIC [e-mail]
RECEIVED
Wednesday, September 4, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
Brandon Helgeson/PIIC [e-mail]
Bradley Mullins/PIIC [e-mail]
Val Steiner /PIIC [e-mail]
Kyle Williams/PIIC [e-mail]

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IPUC Data Request 65 – 1st Revised

IPUC Data Request 65

Please provide the following information for the IKL-Fall Creek Hatchery project
referenced on Page 8.5.3 Exhibit No. 48 of McCoy’s Testimony. Please include
any available workpapers with formulas intact. If any of the information requested
below cannot be provided or is not available, please explain why it is not
available or cannot be provided.

(a) Please provide a detailed explanation for the need of the project including the
analysis justifying the need.

(b) Please provide a list of all the potential alternatives the Company considered
to fulfill the need and explain why the project was selected among the
alternatives supported by the Company’s economic analysis (costs and
benefits) comparing them.

(c) If an RFP or RFQ was submitted, please provide the following:

i. A copy of the RFP or RFQ that was submitted.

ii. A detailed explanation of the selection process including the scorecard and
list of the criteria used to select the project.

iii. The short-list bidder scorecard.

iv. A copy of the winning bid.

(d) Please provide the approved Initial Project Plan including the following:

i. Initial project scope.

ii. Initial project budget.

iii. Initial proposed schedule.

iv. Evidence that the Initial Project Plan and budget were approved at the
appropriate level.

(e) Please provide the following for the Baseline Construction Project Plan:

i. Baseline project scope.

ii. Baseline project budget broken down by WBS.

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IPUC Data Request 65 – 1st Revised

iii. Baseline project schedule broken down by WBS.

iv. If the baseline construction project scope, budget, and/or schedule
deviated from the Initial Project Plan, please explain the differences,
explain the reason for the change, and provide evidence that the changes
were approved at the appropriate level.

v. Project status reports and action items.

vi. Contractor change orders.

(f) Please provide the following related to completion of the project:

i. Baseline construction budget-to-actual comparison by WBS and by year.

ii. Baseline construction schedule-to-actual comparison by WBS.

iii. For any budget-to-actual cost overages by major WBS category that is
over 5%, please explain the reason for the differences and provide
evidence that the amount was approved at the appropriate level.

iv. Please explain any slips in schedule from the baseline construction
schedule.

1st Revised Response to IPUC Data Request 65

Further to the Company’s response to IPUC Data Request 65 dated August 9,
2024, the Company has become aware that one confidential file provided in
Adobe Acrobat PDF format fails to open, specifically Confidential Attachment
IPUC 65-7, confidential file “Exhibit A.7 Final Construction Schedule
2024.03.31_CONF”. The Company provides this 1st Revised response to provide
a replacement version of confidential file “Exhibit A.7 Final Construction
Schedule 2024.03.31_CONF”. Important note: the Company’s narrative
response and all other attachments provided on August 9, 2024 remain
unchanged and valid.

Please refer to Confidential Attachment IPUC 65 1st Revised.

Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of
Procedure No. 67 – Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IPUC Data Request 65 – 1st Revised

Recordholder: Tim Hemstreet / Robert Roach

Sponsor: Tim Hemstreet